Privacy Policy

1. ABOUT US

Identity: SPRIM GLOBAL PARTNERS, S.L.U. (hereinafter, referred to as “SPRIM”).
Tax Identification Number: B-86232444.
Registered office: C/ Hermosilla, 46. 28001 Madrid (Spain).
Data Protection Officer (DPO): [email protected].

2. INFORMATION AND ACCEPTANCE

By accepting this Privacy Policy, users are informed that their personal data they provide through the website located at the URL https://3ei.eu/ (hereinafter, the “Website“) will be processed by SPRIM, as well as the data derived from their browsing and any other data, they may provide SPRIM with in the future.

The user should carefully read this Privacy Policy, which has been drafted in a clear and simple manner to facilitate its understanding, freely and voluntarily determining whether he/she wishes to provide his/her personal data to SPRIM.

3. MANDATORY PROVISION OF THE DATA

The data requested in the forms on the Website are, in general, mandatory (unless otherwise specified in the required field) in order to fulfil the established purposes.

Therefore, if they are not provided or are not provided correctly, these requests cannot be met, without prejudice to the fact that you may freely display the content of the Website.

4. FOR WHAT PURPOSES WILL THE USER'S PERSONAL DATA BE PROCESSED?

Personal data provided through the Website or other means made available to the users will be processed by SPRIM for the following purposes:

Data provided for the registration as a member of 3EI: the data provided in this form will be processed by SPRIM to manage the registration of the user as a member of 3EI.
Data provided for delivering SPRIM, 3EI and ESCP Business School communications: the data will be processed to manage the sending of communications with relevant information about SPRIM, 3EI and ESCP Business School services and/or events that may be of interest to you.
Data provided through the use of the Website: the data provided through the use of the Website will be processed for the purpose of carrying out the maintenance, support and updating of the Website, as well as for the resolution of possible technical or any other type of incidents that may arise in relation to the same and to draft anonymous statistical reports on access habits and the activity carried out by the users on the Website.

5. WHAT USER DATA WILL SPRIM PROCESS?

SPRIM will process the following categories of user data:

Data provided for the registration as a member of 3EI: Identification data (name and surname); contact details (e-mail address); employment details (job and position).
Data provided for delivering SPRIM, 3EI and ESCP Business School communications: Identification data (name and surname); contact details (e-mail address); employment details (job and position).
Data provided through the use of the Website: location data through IP’s, such as browser or device.

In the event that the user provides data of third parties, he/she declares that he/she has their consent and undertakes to provide them with the information included in the Privacy Policy, exempting SPRIM from any liability in this regard. However, SPRIM may carry out periodic checks to verify this fact, adopting the corresponding due diligence measures, in accordance with data protection regulation.

6. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF USER DATA?

The legal basis for the processing of your personal data will be the following:

Data provided for the registration as a member of 3EI: the legal basis is the performance of the contractual relationship.
Data provided for delivering SPRIM, 3EI and ESCP Business School communications: the legal basis of the processing of such data is the consent of the user given by ticking the corresponding checkbox. This consent may be withdrawn at any time, through the means made available to the users indicated along this Privacy Policy.
Data provided through the use of the Website: the lawful basis of the processing of such data is the legitimate interest of SPRIM in the proper functioning of the Website. In this regard, no specific user data will be processed, but the information will be used in an aggregate form to prevent interference with the rights and freedoms of the users. Likewise, SPRIM has implemented technical security measures to guarantee the privacy and confidentiality of the information processed. If you wish to obtain further information on this processing, you may request it by sending an e-mail to [email protected].

The consents obtained for the aforementioned purposes are independent and the user may withdraw only one of them without affecting the others.

To withdraw such consent, the user may contact SPRIM through the following channels:

E-mail: [email protected].

7. WITH WHICH RECIPIENTS WILL THE USER’S DATA BE SHARED?

The user’s data may be transferred to:

Public Administrations with competence in the matter.
Courts and Tribunals, in the event of specific requests made in accordance with the applicable regulations.
Law Enforcement Forces and Agents, in the event of specific requests made in accordance with the applicable regulations.
ESCP Business School, being this transfer necessary for the correct execution of the programme. In the event that the user has consented to the processing of his/her data for the purpose of receiving commercial communications, the data will also be shared with ESCP Business School for this additional purpose.

Additionally, the data may be accessed by SPRIM’s suppliers, such access being necessary for the proper fulfilment of legal obligations and/or the aforementioned purposes. These suppliers will not process user’s data for their own purposes that have not been previously informed by SPRIM.

In this regard, SPRIM follows strict criteria for the selection of service providers in order to comply with its data protection obligations and undertakes to enter into a processing assignment agreement, as provided by law, whereby it will impose on them, among others, the following obligations: to implement appropriate technical and organisational measures to ensure the security of personal data; to process personal data for the agreed purposes and only in accordance with the documented instructions of SPRIM; and to delete and return the data to SPRIM upon completion of the services.

In the event that the user’s data is transferred internationally to a country or territory outside the European Economic Area, SPRIM guarantees that it will adopt the necessary measures to guarantee the security of your data, in accordance with the provisions of the GDPR in this respect, by signing the corresponding Standard Contractual Clauses.

8. COMMUNICATIONS

Act 34/2002 of 11 July, on Information Society and Electronic Commerce Services, allows commercial communications to be made through the use of the Internet and other electronic means, provided that they can be identified as such, as well as the entity from which they are made.

SPRIM will send commercial communications by e-mail about services of interest to the user, in case the user gives his/her consent. However, SPRIM will offer the recipient the possibility to withdraw the consent given to the processing of his/her data for promotional purposes in each of the commercial communications sent to him/her.

9. DATA RETENTION PERIODS

SPRIM will store users’ personal data only for the time necessary to carry out the purposes for which they were collected, as long as the consent granted is not withdrawn. Subsequently, if necessary, SPRIM will keep the information blocked until the limitation period of any liability that may have arisen as a result of the processing of users’ personal data have expired, at which time the data will be irreversibly erased.

Data provided for the registration as a member of 3EI: data processed for achieving this purpose will be stored during for as long as the user remains a member of 3EI and, when the user cancels his or her subscription, the data will be kept blocked during the limitation period of the liabilities that may arise from the same, this is, five years.
Data provided for delivering SPRIM, 3EI and ESCP Business School communications: data processed for achieving this purpose will be stored as long as the user does not withdraw the consent given for this purpose and, when the does it, the data will be kept blocked during the limitation period of the liabilities that may arise from the same, this is, three years.
Data provided through the use of the Website: data processed for achieving this purpose will be stored for a period of one year. SPRIM may keep the information in an aggregate form, without identifying users, for a longer period.

10. USER LIABILITY

The user:

Guarantees that he/she is over sixteen (16) years old and that the information that he/she provides to SPRIM is true, accurate, complete, and up to date. For these purposes, the user is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to his/her real situation.
Guarantees that he/she has informed the third parties from whom he/she provides his/her data, if he/she does so, of the aspects contained in this document. He/she also guarantees that he/she obtained their authorisation to provide their data to SPRIM for the aforementioned purposes.
He/she will be liable for any false or inaccurate information that he/she provides through the Website and for any damages, direct or indirect, caused to SPRIM or third parties.

11. EXERCISE OF RIGHTS

The user may send a letter to SPRIM, to the address indicated in the heading of this Policy, or by e-mail to the address [email protected], at any time and free of charge, in order to:

Access his/her personal data and obtain confirmation as to whether or not SPRIM is processing personal data concerning the user.
Rectify inaccurate or not complete data.
Withdraw consents granted.
Object to certain processing operations, in particular those based on SPRIM’S legitimate interests.
Request the erasure of his/her data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
Obtain from SPRIM the restriction of data processing when any of the conditions foreseen in the data protection regulations are met.
Request the portability of the data provided by the user in those cases provided for in the regulations.
Contact SPRIM’s DPO at the following address: [email protected].

Additionally, the user has the right to file a complaint regarding the protection of his/her personal data before the Spanish Data Protection Agency through its website (www.aepd.es) at the address Calle de Jorge Juan, 6, 28001 Madrid, when the user considers that SPRIM has infringed the rights recognised by the applicable data protection regulations.

12. SECURITY MEASURES

SPRIM will process the user’s data at all times in the strictest confidence and will maintain the mandatory duty of secrecy with respect to the same, in accordance with the provisions of the applicable regulations, adopting the necessary technical and organisational measures to ensure the security of your data and prevent its alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.

Last update: June 2023.